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FORD MOTOR CO. v. UNITED STATES

Nos. 45091, 45427.

47 F.Supp. 259 (1942)

FORD MOTOR CO. (DELAWARE) et al. v. UNITED STATES.

Court of Claims.

November 2, 1942.

Attorney(s) appearing for the Case

J. Marvin Haynes and Robert H. Montgomery, both of Washington, D. C. (James O. Wynn, of New York City, and C. J. McGuire and W. C. Magathan, both of Washington, D. C., on the brief), for plaintiff.

J. W. Hussey, of Washington, D. C., and Samuel O. Clark, Jr., Asst. Atty. Gen. (Robert N. Anderson and Fred K. Dyar, both of Washington, D. C., on the brief), for defendant.

Before WHALEY, Chief Justice, and LITTLETON, WHITAKER, JONES, and MADDEN, Judges.

LITTLETON, Judge.

The Ford Motor Company (Michigan) was on and prior to May 1, 1920, a wholly owned subsidiary of plaintiff, the Ford Motor Company (Delaware) which, also, was the parent corporation of a large number of other affiliated corporations during the taxable years 1921 to 1926 inclusive.

May 1, 1920 plaintiff, being the owner of 100 percent of the stock of the Michigan corporation, liquidated this wholly owned subsidiary by surrendering all of its...

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